DRAFT May 12, 2008
Reasonable Progress Goals Section of Regional Haze SIP/TIP Template
Draft 2008
Mid-Atlantic/Northeast Visibility Union (MANE-VU)
Note:
This draft contains text that states may or may not choose to adopt in their SIPs. It is a preliminary regional draft and should not be construed to obligate any state to include any particular provision of the draft in its final SIP.
Edited by MARAMA
May 12, 2008
Section 9. Reasonable Progress Goals
Table of Contents
9.1 Consultation and Agreement with Other States’ Goals ##
9.2 Consultation regarding Class I Areas in the State
9.3 Calculation of Uniform Rate of Progress ##
9.4 Reasonable Progress Goals for Class I Areas in the State ##
9.4.1 Consideration of Other Air Quality Requirements
9.4.2 Additional Reasonable Controls within MANE-VU
9.4.3 Additional Reasonable Controls outside MANE-VU
9.5 Visibility Impacts of Additional Reasonable Controls
9.5.1 Modeling Impacts of BART Controls on MANE-VU
9.5.2 Implementation of Low Sulfur Fuel Strategy
9.5.3 Impacts of Reducing Emissions of SO2 from 167 EGU Stacks
9.5.4 Reducing non-EGU SO2 emissions outside MANE-VU by 28 Percent
9.5.5 Implementation of Gas-turbine EGU in Canada
9.5.6 Results of Best and Final Modeling
9.6 Demonstration that the Goals are Based on Reasonable Controls
9.6.1 Best Available Retrofit Technology is Reasonable
9.6.2 Emissions From Specific EGUs are Reasonable
9.6.3 Low Sulfur Fuel Oil Requirements are Reasonable
9.6.4 Additional Emission Reductions Measures Outside MANE-VU are
Reasonable
List of Appendices
Section 9 Reasonable Progress Goals
· Determination of Baseline and Natural Conditions Report
· Description of interstate consultation process.
· “Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas,” by MACTEC, dated June 2007.
· List of key electric generating unit (EGU) stacks identified by MANE-VU (comprising a total of 167 stacks, dated June 20, 2007)
· Description of MANE-VU modeling
· Analysis showing uniform rate of progress is not reasonable and rationale for the State’s determination (if necessary)
· “Documentation of 2018 Emissions from Electric Generating Units in the Eastern United State for MANE-VU’s Regional Haze Modeling, Appendix A,” by Alpine, dated April 2008
9. Reasonable Progress Goals
For each Class I area within the State/Tribe, 40 CFR Section 51.308 (d)(1) requires <States/Tribes name> to establish reasonable progress goals (expressed in deciviews) that provide for reasonable progress towards achieving natural visibility. In addition, U.S. Environmental Protection Agency (EPA) released guidance on June 7, 2007 to use in setting reasonable progress goals. The goals must provide improvement in visibility for the most impaired days, and ensure no degradation in visibility for the least impaired days over the State Implementation Plan (SIP) period. The <States/Tribes name> must also provide an assessment of the number of years it would take to attain natural visibility condition if improvement continues at the rate represented by the reasonable progress goal.
Under 40 CFR Section 51.308 (d)(1)(iv) consultation is required in developing reasonable progress goals. The rule states:
In developing each reasonable progress goal, the State must consult with those States which may reasonably be anticipated to cause or contribute to visibility impairment in the mandatory Class I Federal area. In any situation in which the State cannot agree with another such State or group of States that a goal provides for reasonable progress, the State must describe in its submittal the actions taken to resolve the disagreement. In reviewing the State's implementation plan submittal, the Administrator will take this information into account in determining whether the State's goal for visibility improvement provides for reasonable progress towards natural visibility conditions.
In developing the RPG, the Class I state must also consider four factors (cost, time needed, energy and non-air quality environmental impacts, and remaining useful life). The state also must show that it considered the uniform rate of improvement and the emission reduction measures needed to achieve it for the period covered by the implementation plan, and if the state proposes a rate of progress slower than the uniform rate of progress, assess the number of years it would take to attain natural conditions if visibility improvement continues at the rate proposed.
9.1 Consultation and Agreement with Other States’ Goals
<State/Tribe> consulted with the following states having Class I areas as those states established reasonable progress goals for their Class I areas:
· Maine
· New Hampshire
· Vermont
· New Jersey
· West Virginia <if applicable>
· Virginia <if applicable>
· North Carolina <if applicable>
[Note: Delete your own state from the above list if it is there, and delete any state whose Class I areas are not affected by emissions from your state. The purpose of this list is to show that you agree with OTHER states’ Reasonable Progress determinations.]
<State/Tribe> agrees with the reasonable progress goals established by the above states.
[IMPORTANT: If the state/tribe does not agree, provide information as to the nature of the disagreement and the procedures that will be used to continue to work out the disagreement.]
[Option A States/Tribes Without Class I Areas]
<State/Tribe> does not contain any Class I Areas.
{This is the end of Section 9 for the states without Class I areas.}
[States with Class I Areas must continue on with the remaining sections.]
9.2 Consultation regarding Class I Areas in the State
[Note: This section is needed by Class I states only.]
The following Class I Areas are found in <State name>: <Acadia National Park, Roosevelt/Campobello International Park, Moosehorn Wilderness Area, Presidential Range/Dry River Wilderness Area, Great Gulf Wilderness Area, Lye Brook Wilderness, Brigantine Wilderness>.
In accordance with 40 CFR Section 51.308 (d)(1)(ii), in establishing reasonable progress goals for this (these) area(s), <State/Tribe name> provided the following opportunities for public review of the SIP <insert dates and other information regarding public review of the RPG.
As required by 40 CFR Section 51.308 (d)(1)(iv), in determining a reasonable progress goal for each Class I area discussed above, <State/Tribe name> has consulted with the other States/Tribes, which are reasonably anticipated to cause or contribute to visibility impairment in each of these Class I areas. A description of the consultation process is provided in <appendix location>.
Except as provided in Section 9.3.3, below, the reasonable progress modeling used to establish reasonable progress goals reflects the G2 and Base K 2018 emissions inventories for the VISTAS and Midwest RPO regions, respectively. Based on consultation with those regions, those inventories reflect the measures States in those regions consider to be reasonable to implement by 2018 including CAIR, BART, and other federal and state requirements.
9.3 Calculation of Uniform Rate of Progress
[Note: This section is needed by Class I states only.]
As a benchmark to aid in developing reasonable progress goals, MANE-VU compared the baseline visibility conditions to natural visibility condition in each MANE-VU Class I area and determined the uniform rate of visibility improvement (in deciviews) that would need to be maintained during each implementation period in order to attain natural visibility condition by 2064. The uniform rate of improvement per year needed to achieve natural background visibility conditions is shown in Table 9.1, below. <Comment from SW- The numbers in this table were rounded to tenths after discussion with John Graham. Should the final column also be rounded?>
Table 9.1 Uniform Rate of Progress Calculation
Class I Area / (2000-2004)Baseline Visibility (deciviews) (20% Worst Days) / Natural Visibility Conditions (20% Worst Days) / Deciview Improvement Needed by 2018 (from 2004) / Total
Deciview Improvement Needed by 2064 / Uniform Rate of Improvement Annually
Acadia National Park / 22.9 / 12.4 / 2.4 / 10.5 / 0.174
Roosevelt/Campobello International Park / 21.7 / 12.0 / 2.3 / 9.7 / 0.162
Moosehorn Wilderness Area / 21.7 / 12.0 / 2.3 / 9.7 / 0.162
Presidential Range/Dry River Wilderness Area / 22.8 / 12.0 / 2.5 / 10.8 / 0.180
Great Gulf Wilderness Area / 22.8 / 12.0 / 2.5 / 10.8 / 0.180
Lye Brook Wilderness / 24.5 / 11.7 / 3.0 / 12.8 / 0.212
Brigantine Wilderness / 29.0 / 12.2 / 3.9 / 16.8 / 0.280
Both natural conditions and baseline visibility for the 5-year period from 2000 through 2004 were calculated in conformance with an alternative method recommended by the IMPROVE Steering Committee.[1]
[Option 9.3 A:] As explained below, the reasonable progress goals established for the Class I area(s) in <the State or Tribe> provide for at least as much visibility improvement by 2018 as would be achieved by the uniform rate of progress rate shown above.
[Option 9.3 B:] As explained below, the reasonable progress goals established for the Class I area(s) in <the State or Tribe> do not provide for as much visibility improvement by 2018 as would be achieved by the uniform rate of progress rate shown above, because the uniform rate of progress has been determined to be unreasonable. The analysis below shows how <the State or Tribe> considered the cost of compliance, the time for compliance, the energy and non-air quality impacts of compliance, and the remaining useful life of existing sources in making this determination. The discussion below reflects an assessment of the number of years it would take to attain natural conditions if visibility improvement continues at the rate of progress selected by the state as reasonable.
9.4 Reasonable Progress Goals for Class I Areas in the State
[Note: This section is needed by Class I states only.]
In accordance with the requirements of 40 CFR Section 51.308 (d)(1), this Regional Haze SIP establishes reasonable progress goals for each Class I are in <States/Tribes name> for the period of the implementation plan. Table 9.2, below provides a summary of the Reasonable Progress Goals for Class I areas located within <insert States/Tribes name>.
Table 9.2a Reasonable Progress Goals—20 Percent Worst Days
Class I Area / Baseline Visibility (deciviews) (20% Worst Days 2000-2004) / Reasonable Progress Goals, 20% worst days (expected deciview level by 2018) / Deciview improvement expected by 2018 / Natural Visibility Conditions (20% worst days)Acadia National Park / 22.9 / 19.4 / 3.5 / 12.4
Roosevelt/Campobello International Park / 21.7 / 19.0 / 2.7 / 12.0
Moosehorn Wilderness Area / 21.7 / 19.0 / 2.7 / 12.0
Presidential Range/Dry River Wilderness Area / 22.8 / 19.1 / 2.7 / 12.0
Great Gulf Wilderness Area / 22.8 / 19.1 / 2.7 / 12.0
Lye Brook Wilderness / 24.5 / 20.9 / 3.6 / 11.7
Brigantine Wilderness / 29.0 / 25.1 / 3.9 / 12.2
Table 9.2b Reasonable Progress Goals—20 Percent Best Days
Class I Area / Baseline Visibility (deciviews) (20% Best Days) / Reasonable Progress Goals, 20% best days (deciviews)(expected by 2018) / Deciview improvement expected by 2018 / Natural Visibility (20% best days)
(deciviews)
Acadia National Park / 8.8 / 8.3 / 0.5 / 4.7
Roosevelt/Campobello International Park / 9.2 / 8.6 / 0.6 / 5.0
Moosehorn Wilderness Area / 9.2 / 8.6 / 0.6 / 5.0
Presidential Range/Dry River Wilderness Area / 7.7 / 7.2 / 0.5 / 3.7
Great Gulf Wilderness Area / 7.7 / 7.2 / 0.5 / 3.7
Lye Brook Wilderness / 6.4 / 5.5 / 0.9 / 2.8
Brigantine Wilderness / 14.3 / 12.2 / 2.1 / 5.5
Both natural conditions and baseline visibility for the 5-year period from 2000 through 2004 were calculated in conformance with an alternative method recommended by the IMPROVE Steering Committee.[2] Progress toward the 2018 target will be calculated based on 5-year averages calculated in a nationally consistent manner consistent with EPA’s Guidance for Tracking Progress Under the Regional Haze Rule (EPA-454/B-03-004, September 2003) as updated by the alternative method for calculating regional haze recommended by the IMPROVE Steering Committee.
To determine the RPG in deciviews, MANE-VU conducted modeling with certain control measure assumptions. The control measures reflected in these reasonable progress goals are summarized below. In establishing these reasonable progress goals for 2018, <States/Tribes name> recognizes that contributing states have the flexibility to submit SIP revisions between now and 2018 as they are able to adopt control measures to implement these goals. This long-term strategy to reduce and prevent regional haze will allow each state up to 10 years to pursue adoption and implementation of reasonable and cost-effective NOx and SO2 control measures as appropriate and necessary.
9.4.1 Consideration of Other Air Quality Requirements
40 CFR Section (d)(1)(vi) of EPA’s Clean Air Visibility Rules requires that reasonable progress goals represent at least the visibility improvement expected from implementation of other Clean Air Act programs during the applicable planning period.
As documented in the emissions inventory and long term strategy sections of this SIP, the modeling that formed the basis for reasonable progress goals in MANE-VU Class I Areas included an estimate of all of the other programs required by the Clean Air Act. Further information may be found in those sections of this SIP and in the documentation for the MANE-VU modeling.
9.4.2 Additional Reasonable Controls within MANE-VU
The reasonable progress goals shown above in Table 9.2a and 9.2b represent implementation of the regional strategy adopted by MANE-VU on June 20, 2007 and entitled, “Statement of the Mid-Atlantic/Northeast Visibility union (MANE-VU) Concerning a Course of Action within MANE-VU toward Assuring Reasonable Progress.” As such, these goals are intended to reflect the pursuit by MANE-VU States of a course of action including pursuing the adoption and implementation of the following “emission management” strategies, as appropriate and necessary:
a Timely implementation of BART requirements; and
b A 90 percent or greater reduction in sulfur dioxide (SO2) emissions from each of the electric generating unit (EGU) stacks identified by MANE-VU (Appendix <insert #>—comprising a total of 167 stacks, dated June 20, 2007) as reasonably anticipated to cause or contribute to impairment of visibility in each mandatory Class I Federal area in the MANE-VU region. If it is infeasible to achieve that level of reduction from a unit, alternative measures will be pursued in such State; and
c A low sulfur fuel oil strategy in the inner zone states (New Jersey, New York, Delaware, and Pennsylvania, or portions thereof) to reduce the sulfur content of: